In the 1920 case, Ex Parte in the Matter of Muir, Master of The Gleneden, a British ship was seized by U.S. authorities during World War I under suspicion that it was providing aid to Germany. After the war ended and peace treaties were signed with Germany, Captain Muir sought release of his ship arguing that since hostilities had ceased there was no longer any legal basis for its seizure or continued detention. However, the Supreme Court ruled against him stating that until Congress officially declared an end to hostilities through legislation or treaty ratification (which hadn't happened yet), wartime laws remained in effect and thus justified continued detention of his vessel. This ruling underscored how Congressional action is necessary to formally conclude a state of war even after actual fighting has stopped.

The dissenting opinion in the case of Ex Parte In The Matter Of Muir, Master Of The Gleneden (1920) argued that the majority's decision to uphold a fine against Captain Muir for violating quarantine laws was unjust. They contended that Captain Muir had acted reasonably under difficult circumstances and should not be penalized for his actions. Specifically, they pointed out that he had been forced to dock his ship due to an emergency situation involving a sick crew member who needed immediate medical attention. Furthermore, they noted that there were no clear guidelines or procedures in place at the time regarding how such situations should be handled by sea captains. Therefore, it was unfair to hold him accountable for failing to comply with regulations which were ambiguous and unclear. This dissenting view emphasized the need for fairness and reasonableness when interpreting and applying laws.